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`
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`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`
`———————
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`———————
`
`APPLE INC.,
`Petitioner,
`
`v.
`
`SCRAMOGE TECHNOLOGY LTD.,
`Patent Owner.
`———————
`
`IPR2022-00351
`U.S. Patent No. 10,622,842
`
`
`PETITION FOR INTER PARTES REVIEW
`UNDER 35 U.S.C. § 312 AND 37 C.F.R. § 42.104
`
`
`
`
`
`

`

`
`
`IPR2022-00351 Petition
`Inter Partes Review of U.S. 10,622,842
`
`TABLE OF CONTENTS
`
`PETITIONER’S EXHIBIT LIST .............................................................................. 5
`
`I.
`
`II.
`
`INTRODUCTION ........................................................................................... 6
`
`GROUNDS FOR STANDING ........................................................................ 6
`
`III. NOTE ............................................................................................................... 6
`
`IV. SUMMARY OF THE ’842 PATENT ............................................................. 6
`
`V.
`
`PROSECUTION HISTORY ........................................................................... 8
`
`VI. LEVEL OF ORDINARY SKILL IN THE ART ............................................. 9
`
`VII. CLAIM CONSTRUCTION ..........................................................................10
`
`VIII. RELIEF REQUESTED AND THE REASONS FOR THE
`REQUESTED RELIEF .................................................................................10
`
`IX. DISCRETIONARY DENIAL WOULD BE INAPPROPRIATE .................11
`
`A. Discretionary denial under the Fintiv factors is not appropriate ........ 11
`
`1.
`
`2.
`
`3.
`
`4.
`
`5.
`
`6.
`
`No evidence regarding a stay ................................................... 11
`
`Parallel proceeding trial date ................................................... 12
`
`Investment in the parallel proceeding ...................................... 12
`
`Overlapping issues with the parallel proceeding ..................... 13
`
`Petitioner is a defendant ........................................................... 13
`
`Other circumstances ................................................................. 13
`
`The Fintiv Framework Should Be Overturned................................... 14
`
`Discretionary denial under General Plastic is not appropriate .......... 14
`
`A.
`
`B.
`
`2
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`

`

`IPR2022-00351 Petition
`Inter Partes Review of U.S. 10,622,842
`
`C.
`
`Discretionary denial under 35 U.S.C. § 325(d) is not appropriate .... 14
`
`
`
`X.
`
`IDENTIFICATION OF HOW THE CLAIMS ARE UNPATENTABLE ....15
`
`A.
`
`B.
`
`C.
`
`Challenged Claims ............................................................................. 15
`
`Statutory Grounds for Challenges ...................................................... 15
`
`Ground 1: Claims 1, 2, 5-7, 14-16, and 19-20 are obvious under
`35 U.S.C. § 103 over Suzuki .............................................................. 16
`
`1.
`
`2.
`
`3.
`
`4.
`
`5.
`
`6.
`
`7.
`
`8.
`
`9.
`
`Summary of Suzuki .................................................................. 16
`
`Claim 1 ..................................................................................... 19
`
`Claim 2 ..................................................................................... 28
`
`Claim 5 ..................................................................................... 29
`
`Claim 6 ..................................................................................... 30
`
`Claim 7 ..................................................................................... 32
`
`Claim 14 ................................................................................... 35
`
`Claim 15 ................................................................................... 35
`
`Claim 16 ................................................................................... 36
`
`10. Claim 19 ................................................................................... 37
`
`11. Claim 20 ................................................................................... 39
`
`D. Ground 2: Claim 7 is obvious under 35 U.S.C. § 103 over Suzuki
`in view of Park ................................................................................... 39
`
`1.
`
`2.
`
`The ’842 patent is only entitled to a priority date of
`August 10, 2017. ...................................................................... 40
`
`Summary of Park ..................................................................... 45
`
`3
`
`

`

`
`
`IPR2022-00351 Petition
`Inter Partes Review of U.S. 10,622,842
`
`3.
`
`4.
`
`Reasons to Combine Park with Suzuki .................................... 47
`
`Claim 7 ..................................................................................... 51
`
`XI. CONCLUSION ..............................................................................................54
`
`XII. MANDATORY NOTICES ...........................................................................55
`
`A.
`
`B.
`
`C.
`
`Real Party-in-Interest ......................................................................... 55
`
`Related Matters ................................................................................... 55
`
`Lead and Back-up Counsel and Service Information ........................ 55
`
`CERTIFICATE OF WORD COUNT ......................................................................57
`
`CERTIFICATE OF SERVICE ................................................................................58
`
`4
`
`

`

`
`
`
`
`Ex.1001
`
`Ex.1002
`
`Ex.1003
`Ex.1004
`
`Ex.1005
`Ex.1006
`
`Ex.1007
`
`Ex.1008
`Ex.1009
`
`Ex.1010
`
`Ex.1011
`
`Ex.1012
`
`Ex.1013
`Ex.1014
`
`Ex.1015
`
`Ex.1016
`
`IPR2022-00351 Petition
`Inter Partes Review of U.S. 10,622,842
`
`PETITIONER’S EXHIBIT LIST
`
`U.S. Patent No. 10,622,842
`
`Prosecution History of U.S. Patent No. 10,622,842
`
`Declaration of Dr. Joshua Phinney under 37 C.F.R. § 1.68
`Curriculum Vitae of Dr. Joshua Phinney
`
`U.S. 8,421,574 to Suzuki et al. (“Suzuki”)
`U.S. Patent No. 8,922,162 to Park et al. (“Park”)
`
`Prosecution History of U.S. Patent No. 10,153,666
`
`U.S. Patent No. 10,069,346
`U.S. Patent Publication No. 2010/0203831 to Muth (“Muth”)
`
`U.S. Patent No. 8,687,536 to Michaelis (“Michaelis”)
`
`Redline comparison between U.S. Patent No. 10,069,346
`specification in the issued patent (text taken from USPTO website)
`with the as-filed specification of U.S. Patent No. 10,153,666 (text
`taken from publication 2017/0338697 on the USPTO website,
`which represents the as-filed specification of the ’666 patent).
`
`Reserved.
`
`Reserved.
`Reserved.
`
`Scheduling Order, Scramoge Tech. Ltd. v. Apple Inc., WDTX-6-21-
`cv-00579 (filed Sept. 28, 2021)
`
`Plaintiff’s Preliminary Disclosure of Asserted Claims and
`Infringement Contentions to Apple Inc., Scramoge Tech. Ltd. v.
`Apple Inc., WDTX-6-21-cv-00579 (served Sept. 7, 2021)
`
`
`5
`
`

`

`
`I.
`
`INTRODUCTION
`
`IPR2022-00351 Petition
`Inter Partes Review of U.S. 10,622,842
`
`U.S. Patent No. 10,622,842 (the “’842 patent,” Ex.1001) is generally
`
`directed to wireless power reception via electromagnetic induction, a concept long
`
`known and applied in consumer devices. The claimed “wireless power receiver”
`
`simply recites an obvious arrangement of the components commonly found in
`
`these devices. For example, portable devices already included wireless power
`
`receivers with a coil embedded within a plurality of layers.
`
`Accordingly, pursuant to 35 U.S.C. §§ 311, 314(a), and 37 C.F.R. § 42.100,
`
`Apple Inc. (“Petitioner”) respectfully requests that the Board review and cancel as
`
`unpatentable under (pre-AIA) 35 U.S.C. §103(a) claims 1, 2, 5, 6, 7, 14, 15, 16, 19,
`
`and 20. (hereinafter, the “Challenged Claims”) of the ’842 patent.
`
`II. GROUNDS FOR STANDING
`
`Petitioner certifies that the ’842 patent is eligible for IPR and that Petitioner
`
`is not barred or estopped from requesting IPR challenging the patent claims. 37
`
`C.F.R. § 42.104(a).
`
`III. NOTE
`Petitioner cites to exhibits’ original page numbers. Emphasis in quoted
`
`material has been added. Claim terms are presented in italics.
`
`IV. SUMMARY OF THE ’842 PATENT
`
`The ’842 patent generally relates to a “wireless power receiver.” Ex.1001,
`
`6
`
`

`

`
`Abstract. In particular, the claims of the ’842 patent are directed to a wireless
`
`IPR2022-00351 Petition
`Inter Partes Review of U.S. 10,622,842
`
`power coil embedded within a plurality of layers. Claim 1 recites “a first layer,” “a
`
`wireless power receiving coil on the first layer,” and “a second layer on the
`
`wireless power receiving coil.” The manner in which the wireless power coil is
`
`embedded between the two layers is captured by reciting two separate regions: “a
`
`first region in which at least one of the first layer and the second layer overlaps the
`
`wireless power receiving coil” and “a second region in which at least one of the
`
`first layer and the second layer does not overlap the wireless power receiving coil.”
`
`The claim further recites “a first distance … in the first region is greater than a
`
`second distance … in the second region.” This claimed arrangement is shown in
`
`Fig. 9 below. Ex.1003, ¶¶ 27-28.
`
`second
`region
`
`first region
`
`second layer
`
`wireless power
`receiving coil
`
`first layer
`
`shielding unit
`Ex.1001, Fig. 9 (annotated); Ex.1003, ¶ 27.
`
`
`
`7
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`

`

`IPR2022-00351 Petition
`Inter Partes Review of U.S. 10,622,842
`
`As will be explained below, this arrangement of layers around a wireless
`
`
`
`power receiving coil was well known within the art as of the earliest alleged
`
`priority date of the ’842 patent. Ex.1003, ¶ 29.
`
`V.
`
`PROSECUTION HISTORY
`
`The ’842 patent was filed November 6, 2018 as U.S. Application No.
`
`16/182,258. Ex.1002, 1000. The ’842 patent was filed as a continuation of U.S.
`
`Patent No. 10,153,666 filed August 10, 2017 (’666-C patent), which is identified as
`
`a continuation1 of U.S. Patent No. 10,069,346 filed June 28, 2016 (’346-B patent),
`
`which is identified as a continuation of U.S. Patent No. 9,461,364 filed October 23,
`
`2012 (“’364-A patent”). Ex.1002, 1010-13. The ’364-A patent claims priority to
`
`Korean Application No. 10-2011-0114721 filed November 4, 2011, as illustrated
`
`below. Ex.1002, 1010-13.
`
`Korean
`Filed:
`11-4-11
`
`’364-A
`Filed:
`10-23-12
`
`’346-B
`Filed:
`6-28-16
`
`’666-C
`Filed:
`8-10-17
`
`’842
`Filed:
`11-6-18
`
`
`
`
`1 For reasons that will be explained below in Section X.D.1, the ’666-C patent is
`
`not a continuation, but is in fact a continuation-in-part application because the
`
`specification that was filed as the ’666-C patent included new matter that was not
`
`present in the specification filed with the parent ’346-B patent.
`
`8
`
`

`

`IPR2022-00351 Petition
`Inter Partes Review of U.S. 10,622,842
`
`The Examiner allowed the claims of the ’842 patent in the first Office
`
`
`
`Action but objected to the drawings and specification for lack of antecedent basis
`
`for the claims for “terms such as vertical, perpendicular, overlap, distance, gap, and
`
`region.” Ex.1002, 100-104. In response, the Patent Owner amended paragraphs
`
`[0083]-[0084] of the specification and replaced Figures 9 and 10. Ex.1002, 67-73.
`
`The Examiner subsequently issued a Notice of Allowance, stating that the
`
`prior art did not teach the limitations reciting a first region where layers overlap, a
`
`second region where layers do not overlap, and the distance between layers is
`
`greater in the first region than the second region. Ex.1002, 27-28. The ’842 patent
`
`issued on April 14, 2020. Ex.1002, 16.
`
`VI. LEVEL OF ORDINARY SKILL IN THE ART
`
`A Person of Ordinary Skill in The Art (“POSITA”) in November of 2011
`
`(the alleged priority date) or August 10, 2017 (the date on which the continuation-
`
`in-part application of the patent family was filed2) would have had a working
`
`knowledge of the wireless charging art that is pertinent to the ’842 patent. That
`
`person would have a bachelor’s degree in electrical engineering, or equivalent
`
`training, and approximately two years of experience working in the field of data
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`networking, data networking protocols, and network devices. Lack of work
`
`2 See supra, X.D.1.
`
`
`
`9
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`

`

`
`experience can be remedied by additional education, and vice versa. Ex.1003, ¶¶
`
`IPR2022-00351 Petition
`Inter Partes Review of U.S. 10,622,842
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`19-21.
`
`VII. CLAIM CONSTRUCTION
`
`In an inter partes review, claims “shall be construed using the same claim
`
`construction standard that would be used to construe the claim in a civil action
`
`under 35 U.S.C. 282(b), including construing the claim in accordance with the
`
`ordinary and customary meaning of such claim as understood by one of ordinary
`
`skill in the art and the prosecution history pertaining to the patent.” 37 C.F.R. §
`
`42.100(b). The Board only construes the claims to the extent necessary to resolve
`
`the underlying controversy. Nidec Motor Corp. v. Zhongshan Broad Ocean Motor
`
`Co., 868 F.3d 1013, 1017 (Fed. Cir. 2017). Petitioner submits that for the purposes
`
`of this proceeding, the terms of the challenged claims should be given their plain
`
`and ordinary meaning, and no terms require specific construction.3 Ex.1003, ¶ 30.
`
`VIII. RELIEF REQUESTED AND THE REASONS FOR THE
`REQUESTED RELIEF
`
`Petitioner asks that the Board institute a trial for inter partes review and
`
`
`3 Petitioner does not concede that any term in the challenged claims meets the
`
`statutory requirements of 35 U.S.C. § 112, or that the challenged claims recite
`
`patentable subject matter under 35 U.S.C. § 101.
`
`10
`
`

`

`
`cancel the Challenged Claims in view of the analysis below.
`
`IPR2022-00351 Petition
`Inter Partes Review of U.S. 10,622,842
`
`IX. DISCRETIONARY DENIAL WOULD BE INAPPROPRIATE
`A. Discretionary denial under the Fintiv factors is not appropriate
`
`The six factors considered for § 314 denial strongly favor institution. See
`
`Apple Inc. v. Fintiv, Inc., IPR2020-00019, Paper 11 (PTAB Mar. 20, 2020)
`
`(precedential). The district court case is at an early stage and no trial date has been
`
`set despite the court issuing a scheduling order. Petitioner has diligently prepared
`
`and filed this petition within four months of being served Patent Owner’s
`
`infringement contentions. Ex.1016, 1-2, 7. The petition is also well within the one-
`
`year timeframe allowed by Congress.
`
`1. No evidence regarding a stay
`
`No motion to stay has been filed, so the Board should not infer the outcome
`
`of such a motion. Sand Revolution II LLC v. Continental Intermodal Group –
`
`Trucking LLC, IPR2019-01393, Paper 24 at 7 (PTAB June 16, 2020)
`
`(informative); see also Dish Network L.L.C. v. Broadband iTV, Inc., IPR2020-
`
`01359, Paper 15 at 11 (Feb. 12, 2021) (“It would be improper to speculate, at this
`
`stage, what the Texas court might do regarding a motion to stay…”). Thus, this
`
`factor is neutral on discretionary denial.
`
`11
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`

`

`
`
`IPR2022-00351 Petition
`Inter Partes Review of U.S. 10,622,842
`
`2. Parallel proceeding trial date
`
`The co-pending litigation is at an early stage. The district court recently
`
`issued a scheduling order but did not set a trial date. Ex.1015, 4. Instead, the court
`
`“expects to set this date” at the conclusion of the Markman hearing, scheduled for
`
`March 8, 2022. Ex.1015, 3, 4. Without a trial date, this factor weighs heavily
`
`against discretionary denial. See Sand Revolution II at 8-10, 14 (uncertainty over
`
`district court’s trial date weighed against discretionary denial).
`
`3. Investment in the parallel proceeding
`
`The co-pending litigation is in its early stages, and the investment in it has
`
`been minimal. As mentioned above, a claim construction hearing has not yet
`
`occurred, fact discovery will not close until September 2022, and expert discovery
`
`will not close until November 2022. Ex.1015, 3; see PEAG LLC v. Varta
`
`Microbattery GmbH, IPR2020-01214, Paper 8 at 17 (Jan. 6, 2021). This lack of
`
`investment favors institution.
`
`Moreover, Petitioner only learned which claims were being asserted on
`
`September 7, 2021. See Ex.1016 (infringement contentions). In the intervening
`
`weeks, Petitioner has worked expeditiously to file this petition. Under Fintiv,
`
`Petitioner’s prompt filing “weigh[s] against exercising the authority to deny
`
`institution.” Fintiv, Paper 11 at 11 (“If the evidence shows that the petitioner filed
`
`the petition expeditiously, such as promptly after becoming aware of the claims
`
`12
`
`

`

`
`being asserted, this fact has weighed against exercising the authority to deny
`
`IPR2022-00351 Petition
`Inter Partes Review of U.S. 10,622,842
`
`institution under NHK.”).
`
`4. Overlapping issues with the parallel proceeding
`
`Because the co-pending litigation is in its early stages, Petitioner’s invalidity
`
`positions have not yet been fully developed—only the preliminary invalidity
`
`contentions have been served. Final invalidity contentions are not due until April
`
`19, 2022. Because the extent of overlap is thus speculative at this point in time, this
`
`factor favors institution.
`
`5. Petitioner is a defendant
`
`Petitioner is a defendant in the litigation. That is true of most Petitioners in
`
`IPR proceedings. Accordingly, this factor should not be a basis for denying
`
`institution.
`
`6. Other circumstances
`
`The prior art presented in this Petition renders the Challenged Claims
`
`unpatentable as obvious. The merits of Petitioner’s arguments are strong, and this
`
`factor weighs against discretionary denial.
`
`As such, because the Fintiv factors are either neutral or weigh against
`
`discretionary denial, and because this Petition was filed well before the statutory
`
`bar date, institution should not be denied on discretionary factors.
`
`13
`
`

`

`
`
`IPR2022-00351 Petition
`Inter Partes Review of U.S. 10,622,842
`
`A. The Fintiv Framework Should Be Overturned
`
`Apart from Petitioner’s showing that the Fintiv factors favor institution, the
`
`Fintiv framework should be overturned because it (1) exceeds the Director’s
`
`authority, (2) is arbitrary and capricious, and (3) was adopted without notice-and-
`
`comment rulemaking.
`
`B. Discretionary denial under General Plastic is not appropriate
`
`The ’842 patent has not been challenged in any prior IPR petition, so none of
`
`the General Plastic discretionary institution factors apply to this Petition. See
`
`General Plastic Indus. Co., Ltd. v. Canon Kabushiki Kaisha, IPR2016-01357,
`
`Paper 19 at 16 (PTAB Sept. 6, 2016) (Section II.B.4.i. precedential).
`
`C. Discretionary denial under 35 U.S.C. § 325(d) is not appropriate
`
`Denial under § 325(d) is not warranted because the challenges presented in
`
`this petition are neither cumulative nor redundant to the prosecution of the ’842
`
`patent. The Examiner did not consider any of the references relied upon in this
`
`petition. Moreover, the challenges in this petition are non-cumulative because there
`
`were no prior art rejections during prosecution of the ’842 patent. See generally,
`
`Ex.1002.
`
`14
`
`

`

`
`X.
`
`IPR2022-00351 Petition
`Inter Partes Review of U.S. 10,622,842
`
`IDENTIFICATION OF HOW THE CLAIMS ARE UNPATENTABLE
`
`A. Challenged Claims
`
`Petitioner challenges claims 1, 2, 5-7, 14-16, and 19-20 which correspond to
`
`the claims asserted in the plaintiff’s infringement contentions in the co-pending
`
`litigation. Ex.1016, 1. The earliest alleged priority date of the ’842 patent is
`
`November 4, 2011. The first ground of this petition includes each of the challenged
`
`claims and relies entirely on prior art references that predate the earliest alleged
`
`priority date. However, as shown below in Section X.D.1, the earliest possible
`
`entitled priority date of all claims of the ’842 patent is August 10, 2017. The
`
`second ground challenges claim 7 under prior art that predates the earliest possible
`
`entitled priority date of the ’842 patent. Ex.1003, ¶¶ 31-33.
`
`B.
`
`Statutory Grounds for Challenges
`
`Grounds
`#1
`
`#2
`
`Claim(s)
`1, 2, 5, 6, 7,
`14, 15, 16, 19,
`and 20
`7
`
`Basis
`35 U.S.C. § 103 over Suzuki.
`
`35 U.S.C. § 103 over Suzuki and Park.
`
`
`
`U.S. Patent No. 8,421,574 to Suzuki et al. (“Suzuki,” Ex.1005) was filed as
`
`a PCT application on June 12, 2008 and entered the national stage under 35 U.S.C.
`
`§ 371 on December 16, 2009. It issued on April 16, 2013. Suzuki is prior art under
`
`35 U.S.C. § 102(e) if applying the earliest alleged priority date and 35 U.S.C. §
`
`15
`
`

`

`
`102(a)(1) if applying the earliest possible entitled priority date.
`
`IPR2022-00351 Petition
`Inter Partes Review of U.S. 10,622,842
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`U.S. Patent No. 8,922,162 to Park (“Park,” Ex.1006) was filed December 6,
`
`2011 and issued on December 30, 2014. Park is prior art under 35 U.S.C. §
`
`102(a)(1) if applying the earliest possible entitled priority date.
`
`Petitioner’s analysis also cites additional prior art to demonstrate the
`
`background knowledge of a POSITA and to provide contemporaneous context to
`
`support Petitioner’s assertions regarding what a POSITA would have understood
`
`from the prior art. See Yeda Research v. Mylan Pharm. Inc., 906 F.3d 1031, 1041-
`
`1042 (Fed. Cir. 2018) (affirming the use of “supporting evidence relied upon to
`
`support the challenge”); 37 C.F.R. § 42.104(b); see also K/S HIMPP v. Hear-Wear
`
`Techs., LLC, 751 F.3d 1362, 1365-66 (Fed. Cir. 2014); Arendi S.A.R.L. v. Apple
`
`Inc., 832 F.3d 1355, 1363 (Fed. Cir. 2016).
`
`C. Ground 1: Claims 1, 2, 5-7, 14-16, and 19-20 are obvious under 35
`U.S.C. § 103 over Suzuki
`
`1.
`
`Summary of Suzuki
`
`Like the ’842 patent, Suzuki describes “a secondary side of [a] contactless
`
`power transmission apparatus” that includes “a power receiver 16.” Ex.1005,
`
`Abstract, 4:49-50. Suzuki describes a plurality of layers, as illustrated in Fig. 94
`
`
`4 For the sake of illustration, Fig. 9 of Suzuki is shown rotated 180 degrees (i.e.,
`
`16
`
`

`

`
`below. Ex.1005, Fig. 9; Ex.1003, ¶ 34.
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`IPR2022-00351 Petition
`Inter Partes Review of U.S. 10,622,842
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`radiation layer 174
`
`secondary coil 170
`
`magnetic layer 171
`
`shield layer 172
`
`Ex.1005, Fig. 9 (annotated); Ex.1003, ¶ 34.
`
`
`
`Suzuki explains that its apparatus includes a “secondary coil block 17” that
`
`includes “a magnetic layer 171, a shield layer 172 for shielding electromagnetic
`
`noise, and a heat insulation layer 173, which together are unified with the
`
`secondary coil 170.” Ex.1005, 6:29-33. Suzuki’s coil 170 is positioned between
`
`
`upside down) throughout this petition to be consistent with the orientation
`
`described in the ’842 patent. Specifically, the ’842 patent describes its power
`
`receiver with the assumption the associated transmitter is “above” the receiver,
`
`whereas Suzuki describes its power receiver with the assumption the associated
`
`transmitter is “below” the receiver. For readability, the reference numerals have
`
`been flipped as well. Ex.1003, ¶ 34.
`
`
`
`17
`
`

`

`
`two layers—a magnetic layer 171 and a radiation layer. The “radiation layer 174
`
`IPR2022-00351 Petition
`Inter Partes Review of U.S. 10,622,842
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`[is] intervened between the battery cover 152 and the secondary coil 170.”
`
`Ex.1005, 9:17-18; Ex.1003, ¶ 35.
`
`As shown in Fig. 9 below, the red double-sided arrow illustrates a point at
`
`which the distance between the magnetic layer 171 and radiation layer 174 in a
`
`first region (where the layers and coil overlap), which is greater than the near-zero
`
`distance between the same layers in a second region (where the layers and coil do
`
`not overlap). Ex.1003, ¶ 36.
`
`first region
`
`second region
`
`radiation layer 174
`(second layer)
`wireless power
`receiving coil 170
`magnetic layer 171
`(first layer)
`
`shielding unit
`
`second distance
`between first and
`second layer in
`the second region
`
`first distance
`between first and
`second layer in the
`first region
`Ex.1005, Fig. 9 (cropped, annotated); Ex.1003, ¶ 36.
`
`
`Accordingly, Suzuki demonstrates that wireless power receivers were known
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`in the prior art to include a variety of layers arranged with a wireless power
`
`receiving coil between layers as claimed in the ’842 patent. Ex.1003, ¶ 37.
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`IPR2022-00351 Petition
`Inter Partes Review of U.S. 10,622,842
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`2.
`[1.0] A wireless power receiver, comprising:
`
`Claim 1
`
`Suzuki describes a “contactless power transmission apparatus” that includes
`
`a power transmitter and a power receiver 16 (“wireless power receiver”). Ex.1005,
`
`4:46-59 (“The apparatus 1 is broadly divided into a power transmitter 11 in a
`
`primary side and a power receiver 16 in a secondary side.”). “The transmitter 11
`
`and the receiver 16 include primary and secondary coils 120 and 170 capable of
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`electromagnetic coupling, respectively, and are configured to transmit electric
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`power from the primary side to the secondary side by electromagnetic induction
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`between the primary and secondary coils 120 and 170 … The transmitter 11 and
`
`the receiver 16 are, but not limited to, a charger 10 (a primary device) and a cell
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`phone 15 (secondary device), respectively.” Ex.1005, 4:46-59; Ex.1003, ¶ 38.
`
`wireless power receiver
`
`Ex.1005, Fig. 2, Ex.1003, ¶ 38.
`Suzuki’s secondary coil 170 is part of secondary coil block 17. The
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`“secondary coil block 17 in the secondary side further includes a magnetic layer
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`IPR2022-00351 Petition
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`171, a shield layer 172 for shielding electromagnetic noise, and a heat
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`insulation layer 173, which together are unified with the secondary coil 170.”
`
`Ex.1005, 6:29-46. Suzuki’s secondary coil block is shown in Fig. 9 below.5
`
`Ex.1003, ¶ 39.
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`coil block of
`wireless power
`receiver
`
`Ex.1005, Fig. 9 (annotated); Ex.1003, ¶ 40.
`
`
`Suzuki’s power receiver is a wireless power receiver because it is described
`
`as part of a contactless power transmission apparatus. Ex.1003, ¶ 41.
`
`
`5 The analysis herein relies on the embodiment of Fig. 9, which adds the radiation
`
`layer 174. However, the description of Fig. 3 is applicable to the embodiment of
`
`Fig. 9. Ex.1005, 9:13-15 (“For the purpose of clarity, like kind elements are
`
`assigned the same reference numerals as depicted in the first embodiment.”).
`
`Ex.1003, ¶ 40.
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`Thus, because Suzuki teaches a contactless power transmission apparatus
`
`
`
`that includes a power receiver, Suzuki renders obvious a “wireless power receiver”
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`as claimed. Ex.1003, ¶ 42.
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`[1.1] a shielding unit;
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`Suzuki’s power receiver includes “a shield layer 172 for shielding
`
`electromagnetic noise.” Ex.1005, 6:29-46. The “shield layer 172 is, for example,
`
`copper foil or aluminum foil.” Ex.1005, 7:40-42. Suzuki’s shield layer is shown
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`below in Fig. 9. Ex.1003, ¶¶ 43-44.
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`shielding unit
`
`Ex.1005, Fig. 9 (annotated); Ex.1003, ¶ 43.
`Thus, because Suzuki teaches a shield layer, Suzuki renders obvious “a
`
`
`
`shielding unit” as claimed. Ex.1003, ¶ 45.
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`[1.2] a first layer on the shielding unit;
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`Suzuki teaches that its secondary coil block “includes a magnetic layer 171”
`
`(“first layer”) on the shielding unit 172. Ex.1005, 6:29-46. The magnetic layer and
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`the shield layer are laminated together. Ex.1005, 6:29-46 (“The shield layer 172 is
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`IPR2022-00351 Petition
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`also laminated on at least the upper surface of the magnetic layer 171.”). Ex.1003,
`
`¶ 46.
`
`magnetic layer 171
`(first layer)
`
`shield layer
`
`Ex.1005, Fig. 9 (annotated); Ex.1003, ¶ 46.
`
`Thus, because Suzuki’s device includes a magnetic layer 171 on the shield
`
`layer 172, Suzuki renders obvious “a first layer on the shielding unit” as claimed.
`
`Ex.1003, ¶ 47.
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`[1.3] a wireless power receiving coil on the first layer;
`
`Suzuki teaches a secondary coil 170 (“wireless power receiving coil”) on the
`
`magnetic layer 171: The “secondary coil 170 is a planar coil and the magnetic
`
`layer 171 is laminated on at least one side (an upper surface) of the secondary
`
`coil 170.” Ex.1005, 6:29-46. Suzuki further states that “at least the magnetic layer
`
`may be laminated on one side of the secondary coil and unified with the secondary
`
`coil.” Ex.1005, 6:29-46; Ex.1003, ¶ 48.
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`wireless power
`receiving coil 170
`magnetic layer 171
`(first layer)
`shielding unit
`
`Ex.1005, Fig. 9 (annotated); Ex.1003, ¶ 48.
`Thus, because Suzuki teaches a secondary coil 170 on the magnetic layer
`
`
`
`171, Suzuki renders obvious a “wireless power receiving coil on the first layer” as
`
`claimed. Ex.1003, ¶ 49.
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`[1.4] a second layer on the wireless power receiving coil;
`
`Suzuki teaches a second layer in the form of a radiation layer 174 on the
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`secondary coil 170, as shown in Fig. 9 below. Ex.1005, 9:16-24. Specifically,
`
`Suzuki explains that the power receiver “further includes a radiation layer 174
`
`intervened between the battery cover 152 and the secondary coil 170 in order
`
`to improve radiation characteristics from the battery cover 152.” Ex.1005, 9:16-24;
`
`Ex.1003, ¶ 50.
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`radiation layer 174
`(second layer)
`wireless power
`receiving coil 170
`magnetic layer 171
`(first layer)
`shielding unit
`
`Ex.1005, Fig. 9 (annotated); Ex.1003, ¶ 50.
`
`
`
`
`
`
`
`Thus, because Suzuki teaches a radiation layer 174 on the coil 170, Suzuki
`
`renders obvious a “wireless power receiving coil on the first layer” as claimed.
`
`Ex.1003, ¶ 51.
`
`[1.5] a first region in which at least one of the first layer and the second layer
`overlaps the wireless power receiving coil in a vertical direction perpendicular to
`an upper surface of the shielding unit; and
`
`First, Suzuki teaches a region in which the magnetic layer 171 (“first layer”)
`
`is below the coil 170 and the radiation layer (“second layer”) is above the coil 170,
`
`as shown in Fig. 9 below. Ex.1003, ¶ 52.
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`first region
`
`radiation layer 174
`(second layer)
`wireless power
`receiving coil 170
`magnetic layer 171
`(first layer)
`
`shielding unit
`
`Ex.1005, Fig. 9 (annotated); Ex.1003, ¶ 52.
`
`Second, Suzuki also illustrates in Fig. 9 that each of the magnetic layer 171
`
`(“first layer”) and the radiation layer (“second layer”) overlaps the wireless power
`
`receiving coil 170 in a vertical direction perpendicular to an upper surface of the
`
`shielding layer. Ex.1003, ¶ 53.
`
`first region
`
`radiation layer 174
`(second layer)
`wireless power
`receiving coil 170
`magnetic layer 171
`(first layer)
`shielding unit
`Vertical direction perpendicular to
`the upper surface of shield layer
`Ex.1005, Fig. 9 (annotated); Ex.1003, ¶ 53.
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`Thus, Suzuki renders obvious “a first region in which at least one of the first
`
`
`
`layer and the second layer overlaps the wireless power receiving coil in a vertical
`
`direction perpendicular to an upper surface of the shielding unit” as claimed.
`
`Ex.1003, ¶ 54.
`
`[1.6] a second region in which at least one of the first layer and the second layer
`does not overlap the wireless power receiving coil in the vertical direction,
`
`Suzuki teaches a region in which neither the magnetic layer 171 (“first
`
`layer”) nor the radiation layer (“second layer”) overlap the coil 170 in the vertical
`
`direction, as shown in Fig. 9. Ex.1003, ¶¶ 55-56.
`
`second
`region
`
`first region
`
`second
`region
`
`radiation layer 174
`(second layer)
`wireless power
`receiving coil 170
`magnetic layer 171
`(first layer)
`
`shielding unit
`Vertical direction perpendicular to
`the upper surface of shield layer
`Ex.1005, Fig. 9 (annotated); Ex.1003, ¶ 55.
`Thus, Suzuki renders obvious “a second region in which at least one of the
`
`
`
`first layer and the second layer does not overlap the wireless power receiving coil
`
`in the vertical direction” as claimed. Ex.1003, ¶ 57.
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`[1.7] wherein a first distance, measured in the vertical direction, between the first
`layer and the second layer in the first region is greater than a second distance,
`measured in the vertical direction, between the first layer and the second layer in
`the second region.
`
`As illustrated in Figure 9, annotated below, the double-sided red arrow
`
`illustrates a point at which the distance between the magnetic layer 171 (“first
`
`layer”) and the radiation layer 174 (“second layer”), which is greater in the first
`
`region than in the second region. Ex.1003, ¶ 58. Specifically, in the first region,
`
`the coil 170 is interposed between the magnetic layer and radiation layer, as the
`
`coil is pressed into the magnetic layer. See e.g., Ex.1005, 8:65-9:1. Whereas, in the
`
`second region, the